Introduction

London is one of the most ethnically diverse and multicultural cities in the world. However, there are groups who suffer poverty, discrimination, or have particular needs, as a result of their race, gender, disability, age, sexual orientation or religion. Addressing the strategic land use, transport and development aspects of these needs is key to ensuring that the planning system is used to its full potential to deliver benefits to all communities. Planning has an important contribution to make to this process and the Mayor’s Spatial Development Strategy, The London Plan (2004), includes policies to promote social inclusion and to help eliminate discrimination by ensuring that the spatial needs of all London’s communities are addressed. It does this by identifying equality target groups and briefly highlighting some of their needs.

The London Plan also recognises the differing spatial needs of immigrants, refugees and asylum seekers, travellers and gypsies and people belonging to particular faith groups. It is vital that the needs of all London’s diverse communities are taken into account and addressed through an inclusive and equalities-led approach to planning. Black Neighbourhood Renewal and Regeneration Network (BNRRN), The Black Londoners Forum (BLF) and London Civic Forum (LCF) worked in partnership to facilitate a consultation event held on 7^th March on the Draft SPG to provide the opportunity for voluntary and community organisations to come together with public and private sector bodies to comment on the draft equalities and diversity SPG.

We believe that it is essential to consult those belonging to target equality groups on the draft SPG as it is these communities that can suitably advise on equality and diversity policies in relation to their spatial needs. We also hoped that the consultation would allow those working within planning in the public/private sector to comment on policies and tools set out in the SPG and also explore issues faced by target equality groups.

Context

The overall aim of the “Draft Equalities SPG Consultation” was to bring together Londoners, Borough Planners, the GLA and the voluntary and community sector in an information sharing session focusing on the spatial needs of target groups identified in the London Plan and to provide delegates with an opportunity to contribute to the development of policy with regard to equalities implications.

The objectives of the consultation were to:

• Develop a practical understanding of the key spatial issues and needs facing London’s diverse communities.

• Giving equality groups the chance to have an input into both the SPG and the wider planning processes. Creating a platform for Londoners to discuss the key policies and submitting a collective response.

• Identifying practical and good practice solutions to build community capacity in existing professional approaches and services.

The consultation included a presentation by Shelley Gould from the GLA outlining the purpose of the SPG and the key points covered. This was followed by presentations from the panel which consisted of Patrick Anderson from Planning Aid who discussed how communities and individuals can engage in the planning process; Peter Eversden from the London Forum of Amenity and Civic Societies discussed issues centred on community empowerment and community engagement within the planning process; and Tony Wilson from Path UK introduced an initiative called ‘Tomorrow’s Planners’ which is a training programme that seeks to assist BME groups to enter the planning profession. This was followed by four specific workshops based on themes within the SPG:

1)    Community Engagement and Participation

2)    Planning and discrimination

3)    Housing

4)    2012: Understanding the Impact of Planning Developments in London

This response incorporates points made during discussions and workshops, in relation to policy recommendations within the SPG and equality and diversity needs.

2.2 Planning and discrimination

SPG Implementation Point 2a: Promoting equality in planning processes.

Boroughs are recommended to have policies in place so that planning applications can be refused, amended or approved if conditions of diversity and equality have not been properly addressed.

We welcome Implementation Point 2a as a method by which borough planners can ensure that equality and diversity is addressed in planning applications and for them to be carried forward – boroughs need to be encouraged to have policies like this in place and make sure that these policies are put into use. Despite this there is ambiguity in regards to the types of policies boroughs are encouraged to implement which the SPG can go further in recommending, as well as what they should include and how far they can be taken.

2.6 Equality and diversity in the planning profession

SPG Implementation Point 2g: Encouraging diversity in planning departments in London

Boroughs are asked to follow best practice in recruitment and procurement procedures to ensure that services are provided by staff who are representative of local communities.

Planning departments need to be made more diverse in order to deal with equality and diversity issues sufficiently, which the SPG supports. One avenue that could be explored is to set up interim advisory groups that act as a specialist advisory group dealing with equality groups and their needs and which supplement planning departments.

2.4 Effective Community Engagement

SPG Implementation Point 2d: Identifying the issues in Community Involvement.

Boroughs are asked to consult with, and engage, local communities including people from the target groups covered in this SPG throughout the plan making process and in decision-making.

Community engagement and participation was a fundamental dimension to the SPG consultation event and a workshop was held on this issue. The SPG highlights the need for local authorities to be more proactive in engaging local communities, especially equalities groups, to reduce inequalities and discrimination within the planning process. This was also reflected within workshop discussions which reinforced the need for local authorities to be more proactive in including the community but also that the community needs to be proactive in getting their voice heard.

Statements of Community Involvement (SCI) are a key element to facilitating this relationship between the community and their local authority. Statements of Community Involvement are developed by Local Authorities and set out how the community will be involved in preparing Local Development Documents; the SCI needs to be referred to when making plans and minimum requirements set out within the SCI need to be met. The SPG clearly needs to encourage Local Authorities to develop a SCI, keep them up to date, consult upon the community when developing the document, and most importantly, ensure that the community knows that it exists and how it can be put into use. The lack of community knowledge on processes and procedures in place to promote community participation acts as a considerable barrier to community involvement within the planning process. There needs to be much more attention given to simplifying the planning process for communities in order to make planning overall more inclusive and to avoid discrimination within planning.

A major obstacle to community engagement within the planning process is that those affected by planning applications in their local area do not know their rights and do not understand the planning process – outreach work by planning officers would help to get the community engaged and to simplify the planning process.

It would be beneficial to include case studies within the SPG highlighting cases of best practice whereby local authorities have effectively engaged the local community acting as reference points for local authority planners/developers. Signposts could also be included directing those involved in the planning process towards points of advice, issues to take into consideration and barriers to overcome in engaging local communities. The SPG acknowledges that:

“Consultation methods in the planning process which rely mainly on the written form are not appropriate for engaging with all communities. Some people will not want to offer written comment but would be happy to participate in a public meeting or workshop.”

Despite this, greater detail is needed in the form of signposts/case studies of alternative consultation methods and methods by which consultations are publicised. Different ways to reach local people are needed taking into consideration language and IT barriers. In many cases consultations are often publicised on the internet when many older people in particular do not have access to the internet or are not IT literate. There also needs to be a greater focus upon the need for consultation methods in different languages and not solely based on a written form. This is particularly important when considering diverse populations who may not speak or read English or read material in their own language, and who are less likely to engage with consultations in the written form. Inaccessible language and the lack of information provided by boroughs in regards to planning issues deepen the extent of discrimination and inequality within the planning sector. However, efforts to consult the local community are merely seen as tokenistic gestures whereby voices are heard but not listened to. More needs to be done to re-establish community confidence within the planning system.

There is a lack of engagement and participation from young people within the planning process which is neglected within the SPG. Consultation is often an off-putting term for young people. Those working with the Council on planning matters need to go into schools, youth clubs etc. and ask the views/needs of young people. Young people can be engaged through organising community events like ‘melas’ as a fun way through which to get young people involved. This target equality group needs to be empowered and given the opportunity to contribute to the planning and design process in their local area. Youth involvement in shaping areas generates greater respect for the urban environment. This also demonstrates that different methods of consulting.

2.5 Equality Impact Assessments

SPG Implementation Point 2f: Equality Impacts and Action Plans

Boroughs should consider the use of equality impact assessment (either separately or as part of integrated impact assessments) on all statutory land use plans and development briefs.

Carrying out Equality Impact Assessments for each target group is important in establishing and resolving negative impacts of developments and positively encourages developers and planners to consider the impact of developments on the different equalities groups. A recommendation is that Equality Impact Assessments are tied in with Environmental Impact Assessments- which hold more weight within the planning process. There is an Equality Impact Assessment for the ‘Further Alterations to the Mayor’s London Plan (2006)’ and perhaps a reference to this document within the SPG is needed.

2.3 Understanding local communities
SPG Implementation Point 2b: Baseline statistics.

Boroughs are advised also to identify the relevant issues facing different target equality groups based on their own data, the strategic data and the strategic issues…These should be cross-referenced to wider equality issues and to Community Strategies.

A strong recommendation is to tie together supporting statutory documents (like the SCI and EIA). The SPG fails to do this when it has the potential to play a critical role in promoting such documents and their development, and demonstrating the importance of borough planners/developers to consult upon these documents in synchronisation. The SPG should take greater steps towards referring to statutory documents and establishing connections between them so that different structures are taken into consideration when making decisions. For example, when conducting Equality Impact Assessments planners/developers should be encouraged to consult upon the Statement of Community Involvement.

3.6 Access to appropriate and affordable housing

London Plan Policy 3A.4 Housing choice

UDP policies should seek to ensure that all new housing is built to ‘Lifetime Homes’ standards.

We welcome the encouragement of all new housing to be built to ‘Lifetime Homes’ standards allowing the elderly and disabled people to remain in their homes for longer.  A workshop was held to discuss housing issues within the SPG, delegates commented on the fact that current housing should also fit ‘Lifetime Homes’ standards. This is fundamental in maintaining a sustainable housing stock however it is recognised that there are considerable barriers in adapting current housing to ‘Lifetime Homes’ standards and it would be easier to adopt this standard for new housing developments.

There is a substantial lack of detailed guidance on housing within the SPG. Although it is recognised that this is perhaps due to the fact that there is a separate Supplementary Planning Guidance document on Housing, there needs to be specific and detailed guidance on equalities and diversity issues within housing incorporated into the Equalities SPG. This is currently lacking in the ESPG which does not adequately address issues/barriers equalities and diversity groups in particular face within the housing market. Housing policy clearly plays a dual role in not only aiming to provide access to appropriate and affordable housing but to promote community cohesion, social inclusion and reduce inequality and discrimination. Section 3.2 Overarching principles: planning for equality recognises that spatial planning has a role in ‘Promoting Equality of Opportunity (SPG Implementation Point 3c)’ and ‘Promoting Community Cohesion’ (SPG Implementation Point 3d). However, the ESPG section on housing fails to address these themes and their relation to housing policy as well as equality and diversity.

Boroughs should be recommended to develop a borough specific BME housing strategy especially in those areas with a large ethnic/diverse population. The London Borough of Harrow has a BME housing strategy in place (supplemented by action plans) which allows for a housing strategy to be developed that considers the characteristics of the populations, assesses their housing needs and evaluates ways in which this can be implemented. Also, as with Equality Impact Assessments, when assessing housing needs the SCI should be referred upon to provide some advice to planning officers on how to consult upon housing needs – the SPG fails to make this link with statutory documents.

London Plan Policy 3A.4 Housing choice

UDP policies should seek to ensure that all new housing is built to ‘Lifetime Homes’ standards.

Greater clarity is needed in regards to the definition of ‘Lifetime’ homes. The definition of ‘lifetime’ is taken by many to refer to life span when in fact ‘Lifetime Homes’ aim to allow residents to remain in their homes for longer by making housing more flexible especially for elderly and disabled people in transitional stages within their lives.

4.1: The target equality groups

The categorisation of target equality groups doesn’t allow for the intersection of target equality groups, for example Black, Asian and Minority Ethnic women may face different spatial issues than ‘Black Asian and Minority Ethnic People’ and ‘Women’ in general. In the same way disabled and deaf people from BAME groups may face different issues that need to be considered independently which the SPG fails to address. There are also overlapping needs across equalities groups and the SPG needs to take steps to deal with associated issues in a holistic instead of a piecemeal way.

Implementation

Considering that this SPG provides more detailed guidance on how to implement the key London plan policies relating to addressing the needs of target groups identified in the London Plan we believe it is essential that the SPG on equality and diversity in London is signposted to practitioners within the London Plan to encourage its implementation and reinforce its importance. Other statutory documents including the (SCI) can be used to both implement and review issues covered within the SPG.

1.6 Monitoring equalities issues in planning

The SPG acknowledges that borough planners will not be able to adequately implement issues raised in the SPG or adequately provide services catered for the population without up-to-date and relevant data regarding the composition of the population; this will determine the key spatial issues that need to be considered for the population within the area and how they will be addressed. SPG Implementation point 2b recommends for boroughs to compose baseline statistics and maintain accurate data on the local population and this is fundamental in being able to analyse key issues and provide adequate services for the local population.

SPG Implementation Point 2b: Baseline Statistics

Boroughs are recommended to maintain accurate data on the make-up of local populations to allow for analysis which impacts. Boroughs are advised to identify the relevant issues facing different target equality groups using data produced from their community strategies

There are some concerns regarding methods by which points within the SPG can be monitored and implemented; the SPG does not act as a legally binding document but as guidance for those involved in the planning process and cannot set quantitative requirements. Despite this efforts can perhaps be made to make recommendations of quantitative requirements that borough planners/developers can take into consideration.

What is the Black Neighbourhood Renewal and Regeneration Network (BNRRN)?

BNRRN provides the link and enabling tools for BAMER organisations to achieve access to and participate in regeneration and renewal initiatives, provide a platform where BME organisations can begin building links with other communities within their locality, provide information and support to members on how to get involved in local initiatives as well as supporting members and their communities on integrating with other BAMER communities and local generic communities.

BNRRN’s overarching aim is to promote equality, social inclusion, cohesion and integration by brokering new opportunities, promoting partnerships and equipping members with the tools required to deliver measurable improvements and bring about permanent change in their communities.

Jaina Patel

Black Neighbourhood Renewal and Regeneration Network

Jaina@bnrrn.org.uk

www.bnrrn.org.uk

What is the Black Londoner’s Forum (BLF)?

BLF is a proactive organisation, which seeks to advance the economic, cultural and social well being of Black and Ethnic minority Londoners. To increase the level of civic engagement within London’s BME communities with the view to making London work for black Londoners. BLF was formed to represent the interests of London’s BME communities at all levels within the Greater London Authority, regional government, central government and other institutions in Greater London. 

Specifically the objectives are to:

• To promote open inclusive debate and issues that affect BME Londoners by bringing together BME organisations from the voluntary and community sector, businesses, faith groups, local  & regional government and other institutions;

• To advise the Mayor, Assembly, other regional and public bodies and institutions on BME communities concerns over policy proposals, policy developments and service development;

Mohamed Kebbay

The Black Londoners Forum

Mohamed@blacklondon.org.uk

www.blacklondon.org.uk

What is London Civic Forum (LCF)?

LCF engages the capital's civil society in the regional governance of London through democratic debate and effective consultation. Through cross-sectoral working groups set up to look at specific policy issues, the Civic Forum informs the Greater London Authority, the London Assembly, and other pan-London organisations, about the issues that affect the lives and opportunities of those who live and work in London. This is led through our projects which include London 2012 (Olympic and Paralympic Games), Promoting Community Cohesion, Combating Discrimination and Prompting Equality, Community Safety and Policing, Active Learning For Active Citizenship and How London Works. We have a membership which has over 1300 organisations in our network drawing on a cross section of organisations from the voluntary and community, private and public sectors which include specialist equalities organisations covering the various equality strands.

Marian Larragy

London Civic Forum

marian@londoncivicforum.org.uk

www.londoncivicforum.org.uk

doncivicforum.org.uk